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FSVP Requirements Compliance Management Set-Up for Brand Owners

Compliance Program Implementation based on 21 CFR 1.500-1.514, 117, 121, and Related Requirements

To establish and maintain a comprehensive FSVP Compliance Management System for a Brand Owner to ensure full compliance with applicable FDA regulations including 21 CFR 117 (Subpart G), 121, 101.3, 1.1315, 117.139, 117.315, 117.435, 117.475, 117.335, 117.126, and 120.8, and applicable sections of 21 USC 301.

Scope of Work

FSVP Compliance Program

Develop, implement, and maintain a comprehensive Foreign Supplier Verification Program (FSVP) in accordance with 21 CFR 1.500–1.514. This includes the creation of program documentation, procedures, and ongoing verification workflows. This program is established during the initial set-up phase and reviewed annually for regulatory alignment and updates.

Supply Chain Program Assessment

Conduct supplier assessments and raw material risk evaluations following the standards outlined in 21 CFR 117.405, 117.410, 117.415, 117.420, 117.425, and 117.430. Verification activities are selected based on risk and performed semi-annually or upon the onboarding of new suppliers.

FSVPQI Remote Supplier Verification Assessment

Conducted in accordance with 21 CFR 117.435, this service provides risk-based remote assessments of foreign suppliers. It includes a review of food safety documentation, preventive controls, and optional virtual interviews. High-risk suppliers are assessed annually; moderate to low-risk suppliers biennially. A detailed verification report with corrective actions ensures compliance with FDA requirements—supporting regulatory readiness without the need for onsite audits.

Specification Program & Management

Establish and manage product specifications for raw materials, in-process materials (WIP), packaging, labeling, and finished goods in line with 21 CFR 117.475. These specifications are reviewed quarterly to ensure consistency and compliance.

Food Defense / Intentional Adulteration Mitigation Strategies

Perform vulnerability assessments and identify actionable process steps and mitigation strategies according to 21 CFR 121.126 to 121.135. This food defense protocol is reviewed and updated annually or immediately after an incident or process change.

Recall Plan Development and Effectiveness Checks

Develop and maintain a detailed recall plan that includes notification procedures, effectiveness checks, and proper disposal methods as per 21 CFR 117.139. The plan is reviewed annually and tested semi-annually to ensure it remains functional and effective.

Label Identity Compliance

Review product labels to ensure they meet FDA requirements for food identity labeling under 21 CFR 101.3. Each new product or any formulation change requires a new compliance review for proper representation and exemption considerations.

Record Retention & Documentation Control

Maintain all required documentation and verification records with traceable, version-controlled systems in compliance with 21 CFR 117.315 and 117.430. Documentation is managed on an ongoing basis, with monthly updates and an annual audit of all records.

Written Assurance Management

Draft and maintain written assurance agreements with contract manufacturers, co-manufacturers, and suppliers to confirm the implementation of supply-chain-applied controls. This is required under 21 CFR 117.335 and must be updated for each new agreement or annually.

Traceability Plan Development and Maintenance

Establish and maintain traceability records for high-risk food products in compliance with 21 CFR 1.1315. This includes recordkeeping systems, traceability plan components, and food establishment responsibilities. The plan is reviewed annually or when new covered products are introduced.

Food Safety/HACCP Plan Implementation

Implement and maintain a written Food Safety or HACCP Plan based on 21 CFR 117.126 and 21 CFR 120.8. This includes conducting hazard analysis, identifying preventive controls, setting monitoring and verification procedures, and establishing recordkeeping. The plan is reviewed initially, annually, and post-incident.

Emergency Response & Food Security Strategy

Create and maintain a food safety and crisis response plan to address events such as recalls, contamination, and intentional adulteration, as required by 21 USC 301. This plan is reviewed annually to ensure readiness and compliance.

SOP Development, Customization & Client Engagement

Develop standard operating procedures (SOPs), policies, and forms with customized branding, formatting, and document control per internal SOP standards. Engage the client for feedback and revisions. This process is performed during initial implementation and updated as required.

Training and Capacity Building

Develop training materials and deliver training sessions covering FSVP responsibilities, supplier verification, hazard identification, food defense, and documentation protocols. Training is provided quarterly or during onboarding of new personnel, following the guidelines of 21 CFR 117.4 and 121.160.

Deliverables

FSVP Compliance Package

Includes a complete FSVP Program available in digital and/or print format. The package contains all required SOPs, company-specific policies, and verification forms essential for meeting FDA regulatory compliance requirements.

Customized SOPs & Compliance Documents

Includes the following: Foreign Supplier Verification SOPs, Supplier Audit Procedures, Risk Analysis Matrix, Product Specification Templates, Food Defense SOPs, Recall SOPs, HACCP/Food Safety Plan, Written Assurance Forms, and Traceability Forms.

Audit & Verification Reports

Comprehensive set of audit forms and training materials used for supplier verification and compliance evaluation. Includes Audit Templates and Reports, Supplier Evaluation Scorecards, and Food Safety Compliance Risk Logs to support regulatory readiness and continuous improvement.

Records Management

Covers critical documentation control, including Documentation Logs, Version-Controlled Record Indexes, and Annual Review Checklists to ensure traceability and accountability.

Label Compliance Assessment

This service provides internal tools—not a regulatory review—for identifying labeling non-conformances and tracking revisions. It includes structured forms and assessment checklists such as Product Label Review Forms and 101.3 Identity Compliance Checklists, helping teams evaluate labels against FDA requirements and maintain accurate, up-to-date product information.

Training Package by TrainingAce.pro

Delivered through TrainingAce.pro, this package includes comprehensive training materials such as Presentation Decks, Quizzes, Evaluations, Attendance Logs, and Certificates. Designed to support internal training requirements and enhance staff awareness, these resources ensure consistent knowledge transfer and regulatory preparedness across teams.

Client Engagement Support

Client engagement tools include SOP Client Presentation Decks, Meeting Summaries, and Change Request Logs to facilitate collaboration and feedback throughout the implementation process.

Fees and Subscriptions

Standard Compliance Package – $5,950 USD (One-Time Set-Up Fee)

Includes:

• FSVP Program Customization (Per Product Line & Supplier) • Supply-Chain Risk Assessment and Supplier Verification Plan • Drafting of SOPs, Policies, Checklists, and Compliance Forms • Food Defense (IA Rule) Vulnerability Assessment & Mitigation Strategy • Recall Plan Preparation with Effectiveness Checks • HACCP / Food Safety Plan (117.126/120.8) • Written Assurance Agreements with Co-Manufacturers/Suppliers • Product Label Compliance Assessment Review Forms • Traceability Plan Setup (1.1315) • Internal Review, Revisions, and Approval Formatting • Client Engagement Meetings & Email Support

Annual Maintenance Package – $2,400 USD / year

Includes:

• Annual Review of FSVP and Supplier Documentation • Annual Risk Reassessment Report • Recordkeeping & Version Control Update

Add-Ons:

• Additional Supplier Setup: +$249/supplier • Additional Product Line Setup: +$149/product • Product Label Compliance Assessment Review (New Product): $150/Label • Traceability Record Support (FSVP High-Risk Foods): $300/setup

Ideal For:

U.S.-based importers, brand owners, or co-packers seeking to establish or upgrade a fully compliant FSVP system tailored to FDA expectations and audit-readiness.

Get Started: Contact us at info@consultareinc.com or submit your request via our online form.